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Union Dues Deductions – Contracts

7th Circuit Court of Appeals

Case Name: Ariadna Baro v. Lake County Federation of Teachers Local 504, IFT-

Case No.: 22-1722

Officials: Rovner, Hamilton, and St. Eve, Circuit Judges.

Focus: Union Dues Deductions – Contracts

Roman Baro was an English-as-a-second-language teacher for Defendant Waukegan Community School District No. 60 (“the District”) in August 2019 when she signed a union membership form—a contract to join Defendant Lake County Federation of Teachers Local 504, IFT-AFT/AFL-CIO (“the Union”), the union that represents teachers in the District. The form authorized the District to deduct union dues from her paychecks for one year. Ramon Baro alleges she learned later that she was not required to join the Union and she tried to back out of the agreement. But the Union insisted that her contract was valid and the District continued deducting dues from her paychecks. In response, Ramon Baro sued arguing that the dues deduction violated her First Amendment rights under Janus v. American Federation of State, County, & Municipal Employees, Council 31, 138 S. Ct. 2448 (2018). The district court dismissed the suit. This court ruled that the First Amendment protects our right to speak. It does not create an independent right to void obligations when we are unhappy with what we have said. Ramon Baro voluntarily consented to the withdrawal of union dues and the enforcement of a valid private contract does not implicate her First Amendment rights.


Decided 01/06/23

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